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Non US Tax Reform

Business taxes internationally are currently going through a period of unprecedented reform. International cooperation bodies such as the OECD and EU are driving and influencing domestic tax policy in a manner not previously seen. Equally, the digitalization of the global economy has called into question the effectiveness of traditional tax measures and is fueling a global debate for the reallocation of taxing rights away from physical presence to better align with value creation. However, tax is  still fundamentally a domestic issue for countries, used to generate revenue, influence economic and social behavior and indeed to compete with other countries.

All of the above factors are driving widespread change to domestic tax systems across the world. There is some general consistency, but many local differences and inconsistencies have resulted in significant additional tax complexity and burden for business.

Key challenges

  • uncertainty
  • historic business models and economics are being called into question
  • new tax measures are being rushed into force without full explanation or supporting guidance
  • legislation/guidance is frequently being modified to address issues identified after introduction
  • inconsistency with how similar transactions are taxed in different jurisdictions
  • tax authorities are becoming increasingly aggressive to secure the largest tax take for their jurisdiction
  • the information disclosure requirements for business are at an all time high
  • tax authorities have become very efficient at sharing information, both materially increasing tax administrative burdens for business and the likelihood as an audit or challenge.

Navigating the changes

More than ever, in this new tax environment each of the changes adopted by a country is a piece in an increasing complex puzzle with which multinationals must grapple.  The Eversheds Sutherland tax team is here to help businesses understand the individual pieces and how they fit together.

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